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Interpretation Response #18-0030

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Lighting Technologies International, LLC

Individual Name: Joe Rodriguez

Location State: CA Country: US

View the Interpretation Document

Response text:

May 21, 2018

Joe Rodriguez
Quality Manager/EH&S Manager
Lighting Technologies International, LLC
13700 Live Oak Avenue
Baldwin Park, CA 91706

Reference No. 18-0030

Dear Mr. Rodriguez:

This letter is in response to your February 27, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of radioactive material. Specifically, you ask whether a material that does not meet the definition of "radioactive material" in § 173.403 may be transported as a non-hazardous material.

In accordance with § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material. This Office generally does not perform this function. Section 173.403 defines "radioactive material" as any material containing radionuclides where both the activity concentration and the total activity in the consignment exceed the values specified in the table in § 173.436 or values derived according to instructions in § 173.433. If a material does not meet this definition, then it is not considered radioactive material under the HMR.

Furthermore, if the material does not meet the definition of any other hazard class or division, it is not considered a hazardous material subject to the HMR and may be transported as a non hazardous material.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
173.22 Shipper's responsibility
173.403 Definitions
173.433 Requirements for determining basic radionuclide values, and for the listing of radionuclides on shipping papers and labels
173.436 Exempt material activity concentrations and exempt consignment activity limits for radionuclides